Object

Representation ID: 8710

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

4.2 Our first concern is that none of the four options deliver LHN+10% (15,060 dwellings). The Table in
7.14 of the draft SA shows that whilst two (Options 3a and 6) come closer to meeting that
requirement by delivering 14,480 dwellings it is still not meeting LHN+10%.
4.3 Our second concern is that new settlements form part of the strategy in 3 of the 4 options.
However, paragraph 2.6 of the Development Strategy Topic Paper states:
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“The results are reported in full in the Issues & Options Consultation - summary
and responses document and the key point was that the (brown) urban,
(yellow) A421 and (pink) rail-based growth development locations were the
most strongly supported and were twice as likely to be selected as suitable
locations for growth as dispersed and new settlement based growth.
4.4 Therefore, the results of the Issues and Options showed that the options for new settlements and
dispersed growth were most unpopular. Despite this, they formed part of 9 of the 13 options in
the draft SA, and 3 of 4 preferred options in the consultation paper. We question the merit in
undertaking consultation at the Issues and Options when at this early stage in LP2040 no
meaningful account has been given to the public responses.
4.5 The third is that paragraph 3.11 recognises that urban growth comes with deliverability issues and
significant investment and the level of development in each of the 4 options for the urban area
are a constant. In that context paragraph 3.6 is clear where it states that:
“the urban area and adjoining urban area perform the best, particularly
because of reducing carbon emissions and reducing travel”.
4.6 Therefore, development in and adjacent to urban areas performs best, yet paragraph 3.7 states:
“The worst performing component was the village related growth component.
It was likely to have a more negative effect than the other components,
particularly in relation to reducing carbon dioxide emissions, protecting water
resources, and reducing the need to travel and promoting sustainable modes
of travel. It was likely to have fewer positive effects than any of the other
components of growth.”
4.7 This conclusion must be read in the context that the Development Strategy Topic Paper which
has a Village Related Growth Option were all based on over 4,000 new homes ranging from 29%
to 47% of the total requirement. We do not advocate such a dispersal strategy but clearly
recommend that there should be growth at Key Service Villages and Rural Service Centres.
4.8 Therefore the options should have assessed a lower total percentage of the total requirement for
the Village Related Growth Option and also distinguished between Key Service Centres and
smaller villages, particularly for Wootton which lies close to Bedford town and close to Milton
Keynes. Whilst other villages may be more remote with fewer facilities, more realistic options/s for
growth at Key Service Centres and Rural Service Centres should have been considered.
4.9 The fourth is that we note that of the 4 preferred options; 3 of which include growth in certain
parishes. These are Options 2a (2,000 dwellings), 2b (1,500 dwellings), 2d (750 dwellings). We note
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that these options state within the parish area rather than within or adjacent to parish settlement.
Paragraph 3.12 states that “development in parishes within the ‘Transport corridor”…. “will not
necessarily adjoin existing villages but could be at new locations between a
parish”. Development on the edge of existing settlements, and closer to services, are important
factors and we consider that the Plan needs to clarify development within a Parish should be
located adjacent to settlement boundaries of existing settlements as that is the most sustainable
option.
4.10 This would also meet the aims and objectives in the Framework, for example;
• Para 16: “Plans should: a) be prepared with the objective of contributing to the
achievement of sustainable development”;
• Para 79: “To promote sustainable development in rural areas, housing should be
located where it will enhance or maintain the vitality of rural communities. Planning
policies should identify opportunities for villages to grow and thrive, especially where
this will support local services. Where there are groups of smaller settlements,
development in one village may support services in a village nearby”. (our emphasis)
4.11 The fifth concern is that the LHN Assessment has been published but there has been no
assessment of housing market areas and commuting patterns to help inform strategy and
location of growth. Generally, Bedford borough has a strong geographical association with
Milton Keynes to the south-west and Central Bedfordshire to the south. This was recognised in the
SHMA (2018) where Bedford is within the Milton Keynes HMA and a commuting association with
Central Bedfordshire. This context should inform the location for new growth in a sustainable
way. Instead, the preferred options appear to focus growth with new settlements in the northeast
of the borough which the SHMA (2018) suggested was closer/within the Huntingdon HMA. We
are concerned that this approach may exacerbate unsustainable travel patterns particularly
where housing growth in more remote parts of the borough may force residents to take longer
journeys into Bedford town for jobs. Higher-order settlements closer to Bedford town should be
prioritised for housing growth in preference to more remote areas.
4.12 The sixth is that it is Intended that if the favoured strategy involves additional development in and
around villages, that parish councils will be asked to allocate land in accordance with
LP2040. This is for non-strategic scale sites but if this is carried forward into LP2040, then each Parish
should be given a housing requirement as required by paragraph 66 of the Framework which
states:
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“66. Strategic policy-making authorities should establish a housing requirement
figure for their whole area, which shows the extent to which their identified
housing need (and any needs that cannot be met within neighbouring areas)
can be met over the plan period. Within this overall requirement, strategic
policies should also set out a housing requirement for designated
neighbourhood areas which reflects the overall strategy for the pattern and
scale of development and any relevant allocations. Once the strategic policies
have been adopted, these figures should not need retesting at the
neighbourhood plan examination, unless there has been a significant change
in circumstances that affects the requirement.” (our emphasis)
4.13 In light of the above we answer paragraph 3.17 which asks:
“If you think that there are other strategies we should be considering, please let
us know. These may be ones set out in the Development Strategy Topic Paper
or completely different alternatives.”
4.14 We consider there are reasonable alternatives that should be considered. They are:
(1) greater growth in larger villages including Key Service Villages alongside urban
growth and transport corridor growth.
(2) an expansion of Option 6, with more growth in Key Service Villages, and to include
urban growth.
4.15 Both these options should distinguish between larger more sustainable villages (KSCs and RSCs)
and smaller ones. In the evidence base there is the Settlement Hierarchy Paper dated September
2018 although we note that there is a “review underway” and is one of the documents “not yet
available for comment, but will be finalised in order to support the plan for submission (2022)”. It
is important that this is the subject of consultation prior to the Submission Plan being published so
that any issues are considered prior to the spatial strategy evolving and reducing any potential
objections to a key part of LP2040.
4.16 Our specific interest is Wootton which is one of the 8 Key Service Centres. Policy 4S of the LP2030
sets out the aim to deliver 970 dwellings per annum across the borough, with a minimum of 3,169
dwellings to be distributed across the various settlements. Part iv states that a minimum of 2,000
dwellings should be located at Key Service Centres of which Wootton is one. The policy then
continues when it states:
“it will be necessary to identify sites to meet the following levels of development,
generally in and around defined Settlement Policy Area boundaries. Other than
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in Roxton, all sites will be allocated in Neighbourhood Development Plans. In
rural service centres allocations may exceed 50 dwellings where specific local
justification is set out in Neighbourhood Plans demonstrating that it would be
appropriate in terms of the scale, structure, form and character of the
settlement and the capacity of local infrastructure”
4.17 Criteria xi to xvi then set out a specific housing requirement for each settlement. However, there
is no specific requirement proposed for Wootton. This was explained in the 2017 version of the
LP2030 because Wootton had expanded in recent years. This should not be seen as further
development at Wootton not being appropriate; rather it confirms its suitability and capacity as
a location for growth. We consider that going forward Wootton should be identified as a location
for growth and given a specific requirement. This should be at least 500 dwellings as set out in
Options 3b, 3c, 4, 5 and 6. That should not mean that all other Key Service Centres are also
required to deliver 500 dwellings as they are already required to deliver 500 dwellings in LP2030
and form part of the committed 13,000 dwellings. These settlements could get less or as was the
case at Wootton zero in LP2030 as LP2040 progresses. What is clear is that Wootton should have
a specific requirement of at least 500 dwellings especially due to its sustainability credentials and
its close relationship to Bedford town.
4.18 Indeed paragraph 2.8 of the committee report of Application 19/00894/MAO (land west of
Wootton Upper School) the LPA states:
“2.8 Despite the lack of allocation for Wootton, this does not mean that
development should not occur.”
4.19 In that context, Policy W2 of the emerging Wootton Neighbourhood Plan states:
“Provision will be made over the plan period for up to 105 homes as proposed
within site specific policies W3 to W6. Development in excess of this figure will
only be permitted where the proposal relates to a site within the SPA in
accordance with Policy W1.”
4.20 That plan is to 2030, yet is not meeting the full need as explained in paragraph 60 of the Wootton
Neighbourhood Plan which states:
“Public consultation was carried out in June/July 2018 on the proposed scale
of development in the WNDP, with 73% of respondents strongly
agreeing/agreeing with the allocation of sites sufficient to accommodate a
total of 145 residential units within the plan period, on the basis of need
ascertained by the Housing Needs Survey. This survey aimed to assess the need
of local people for either affordable housing or market housing in Wootton, at
the time when it was envisaged that the Bedford Borough Local Plan would
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cover the period to 2035. The quantum of development has been marginally
reduced in response to further resident feedback and to reflect the reduced
Local Plan period to 2030.”
4.21 Therefore, the housing need from the evidence base is 145 dwellings. It should be noted that the
105 homes proposed in Policy W2 is seeking to address existing and potential housing needs of
the existing residents of Wootton and it takes no account of the newly forming households and
the increase in households in the plan period across Bedford that the standard method
calculates. This is a particularly important point as the LP2040 consultation confirms that capacity
within Bedford town for housing is limited and the Plan will rely on growth outside of this to meet
needs of which Wootton can play an important role. However, it demonstrates a continuing
need for new housing in Wootton which LP2040 should plan to meet.
4.22 To conclude, there should be changes to the Spatial Options and we propose:
• A greater level of housing to be planned for of LHN+20%;
• Greater recognition of the housing market areas and extensions to existing established
settlements with closer relationships to Bedford town should be prioritised;
• Clarity that extensions to Key Service Centres and other sustainable villages form part
of the strategy. This may be a refinement of the transport corridor criteria or a specific
requirement as set out in part iv and v of Policy 4S of LP2030; and,
• Each neighbourhood plan area to have a requirement set out. For Wootton we
consider at least 500 dwellings.